Call Recording Requirements and Scoring
You must record all sales and enrollment calls made by your agents. This is a CMS requirement and a condition of your contract with carriers. This page covers what you need to record, how to score calls, and what to document.
Which Calls Must Be Recorded?
Record all inbound and outbound calls related to:
Sales calls — Individual plan recommendations for a beneficiary
Enrollment calls — Completing an enrollment application with the beneficiary
Scope appointments — Discussing scope of appointment over the phone
Retention marketing — Any call designed to influence a beneficiary's decision to stay enrolled in their current plan
Benefit discussion calls — Any call mentioning benefits (dental, vision, hearing, premium reduction, cost savings, etc.)
Calls You Don't Need to Record
You don't need to record calls that are just:
Setting up an appointment
Checking in after a completed sale
General customer service
The Disclaimer Rule
Within the first minute of any recorded sales or enrollment call, your agent must read the disclaimer. The disclaimer must state that the call is being recorded.
Example: "This call may be recorded for quality assurance and compliance purposes."
If your agent doesn't read the disclaimer in the first minute, the call is out of compliance — even if the call itself is good.
Scoring Your Calls
Use the Spark Call Recording Scorecard to review and score calls. This tool tracks:
Disclaimer timing (was it read in the first minute?)
Script compliance (did agents follow the script?)
Compliance points (disclosures, required language, etc.)
Overall call quality
Review the TPMO Scripting and Recording Oversight Guide for additional guidance.
Questions About Recording?
If your team isn't sure whether a call needs recording, record it. It's better to over-record than to miss a required call.
Contact us at [email protected] with questions.